Hazardous Waste Management

by

Harold M. Cota, Ph.D., P.E. David Wallenstein TABLE OF CONTENTS

Introduction 1 1.0 Regulatory Overview 1 1.1 RCRA 1 1.2 CERCLA 2 1.3 TSCA 2 1.4 HSWA 3 1.5 Code Of Federal Regulations 3 2.0 Definition OfHazardous Waste .4 2.1 Listed Wastes 4 2.2 Non-Listed Wastes , 4 2.3 Risk Assessment. 5 3.0 Management OfHazardous Wastes 5 3.1 Hazardous Waste Generators 5 3.2 Storage Of Hazardous Waste 6 3.2.1 Underground Storage Tanks 6 3.3 Transportation Of Hazardous Waste 7 3.3.1 Generator Requirements 7 3.3.2 Waste Manifests 8 4.0 Hazardous Waste Treatment 8 4.1 Treatment Options 9 4.2 Selecting A Suitable Waste Treatment Facility 9 4.3 Waste Disposal 10 4.4 Remediation 10 5.0 Infectious Waste Management 10 6.0 Radioactive Waste Management 11 6.1 Sources 11 6.2 Government Involvement 11 6.3 Health Concerns With Radiation Exposure 12 6.4 Disposal/Storage 12 6.5 Management Of LLW 13 6.6 Transportation 13 7.0 Mixed Wastes 14 8.0 Corrective Action 14 9.0 Waste Minimization 15 9.1 Life Cycle Design 15 10.0 Right To Know wws 16 11.0 Computer Usage In Hazardous Waste Management 17 12.0 Recommended Reading 17 Glossary OfKey Terms 18 Further Information 18 INTRODUCTION

Hazardous waste management is a broad and evolving field. Applicable state and federal regulations comprising over 60,000 pages are continually being updated. Many of these regulations overlap and are subject to differences in interpretation that often lead to court rulings. Regulations, economic pressures and public perception are forcing companies to rapidly change the way they manufacture products in order to minimize hazardous waste generation.

Over 200 million tons of solid hazardous waste are generated annually in the United States. Huge quantities of hazardous waste deposited in landfills, ponds, fields, and other locations require removal or in situ treatment. Common hazardous wastes include: SOlvents, acids, bases, heavy metals, pesticides, plating and heat treating wastes. Six major effects of improper hazardous waste management are: groundwater contamination, contamination of surface runoff, air pollution, fIfe and explosion, adverse health effects via direct contact, and via the food chain.

TIlis chapter provides a general overview of federal regulations governing hazardous waste management, as well as a brief review of the types of hazardous waste, waste minimization, and treatment and disposal technologies. Four types of hazardous waste will be discussed here: chemical waste, radioactive waste, infectious waste, and mixed waste.

1.0 REGULATORY OVERVIEW

Federal, state, and local governments regulate hazardous waste management. Federal regulatory agencies sometimes delegate authority to the state agencies provided that the state programs are at least as strict. Only federal regulations are discussed here. With a few exceptions, the Environmental Protection Agency (EPA) governs most federal hazardous waste management activities. The Department of Transportation (DOT) governs the transportation of all hazardous wastes except for High Level Nuclear Waste.

The Nuclear Regulatory Commission (NRC) governs nuclear wastes from the private sector and co­ regulates mixed wastes with the Department of Energy (DOE). Other agencies, such as the Occupational Safety and Health Administration (OSHA) and the Bureau of Land Reclamation, have responsibilities within the hazardous waste management process. Important legislation is summarized below.

1.1 RCRA

Congress passed the Resource Conservation and Recovery Act (RCRA) in 1976 as an amendment to the Solid Waste Act of 1965. RCRA is composed of 10 parts covering all aspects of hazardous waste management with the exception of nuclear waste. It governs generation, storage, transportation, treatment, recycling, and disposal. The generator of hazardous waste is responsible for the waste through each of these steps and beyond. EPA was authorized by RCRA to establish and implement regulations governing hazardous waste management. This involved: (1) defining . hazardous waste, (2) tracking the transportation of the waste, (3) establishing construction and operation standards for treatment, storage and disposal facilities (TSDF's) and (4) establishing guidelines for state hazardous waste management programs. The Medical Waste Tracking Act of 1988 (MWTA) expanded RCRA to include regulating the disposal and treatment of medical waste. 1.2 CERCLA

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was passed in 1980 to address the cleanup of toxic waste sites. CERCLA provides for liability, compensation, cleanup and emergency response to existing and closed hazardous waste sites. The heart of CERCLA is the Superfund that started in 1980 as a $1.6 billion fund. The Superfund Amendments and Reauthorization Act of 1986 (SARA) revised and broadened CERCLA creating a $8.5 billion fund to be collected through special taxes. Congress asserted that regardless of who was responsible for causing the contamination, the sites needed remediation in order to protect human health and the environment.

EPA involvement begins with the identification of a potential hazardous waste site. The EPA has developed the Emergency and Remedial Response Information System (CERCUS) to document all of the sites in the United States that may be candidates for remedial action. As of 1993, the list was approaching 30,000 sites. In order to be eligible for cleanup under CERCLA, a site must first be placed on the National Priorities List (NPL). The NPL identifies the hazardous waste sites of immediate concern and ranks them according to their relative risk to public health and the environment. As of August 1990, 1187 sites were on the NPL list identified as "Superfund sites." . The EPA addresses the clean up of each site on a case by case basis. Part of EPA's process involves the identification of the Potentially Responsible Parties (pRP's) for (1) state or federal remedial action, (2) recovery of necessary response cost incurred, and (3) damages to natural resources. The PRP's may include past owners or operators, generators of the hazardous substances that are at the site, or the transporters who brought the waste to the site. EPA tries to get the PRP's to initiate clean up or to pay for the remediation, but if the PRP's cannot, the EPA uses money from the Superfund for the clean up and tries to recover the monies later. No amount of care can guarantee a person handling hazardous substances protection from liability. The liability cannot be transferred to another party.

Under CERCLA, the EPA can respond to incidents involving hazardous substances in three ways:

1. Immediate removal and emergency response to prevent significant harm (completed within 6 months) 2. Planned removal which is an expedited response to a situation that is not necessarily an emergency 3. Remedial response that requires additional time and money intended to achieve a site solution that is a permanent remedy

1.3 TSCA

The Toxic Substance Control Act (TSCA) was enacted in 1976 to prevent environmentally unsound chemicals such as DDT and PCBs from being released to the environment. TSCA gives the EPA ninety days to investigate the potential deleterious effects of new chemicals on the environment before allowing them to be manufactured. Ifa chemical poses a significant threat, the EPA may impose special restrictions from warning labels to an outright ban. The EPA can also require testing of existing chemicals if there is insufficient information to form a risk assessment.

2 1.4 HSWA

Congress passed the Hazardous and Solid Waste Amendments (HSWA) in 1984. These amendments significantly broadened the scope and effectiveness of RCRA. A major theme of the HSWA is the protection of groundwater through the following:

• hazardous waste landfill design requirements • requirements for small quantity generators • requirements for underground storage tanks • requirements for landfilling of municipal wastes • restrictions on future land disposal • treatment requirements for waste deposited in landfills

Provisions of the HSWA ban the land disposal of specified types of hazardous wastes unless the wastes are first treated to levels that are protective of human health and the environment. The regulations specifically prohibit the disposal of bulk (non-containerized) liquid wastes in landfills and surface impoundments. It prohibits disposal of containerized liquids unless no alternative is available. The amendments set out a series of deadlines for ending land disposal of various groups of hazardous wastes.

There are three exceptions to the land ban:

1. the waste meets EPA and state treatment standards 2. a petitioner demonstrates to the EPA and/or state that the waste in question will not migrate from the disposal unit for as long as the wastes remain hazardous 3. the EPA has issued a variance extending the deadline

In addition, the Occupational Health and Safety Act of 1970, the Hazardous Materials Transportation Act of 1975 (HMTA), portions of the 1970 Clean Air Act and as amended in 1990, the Clean Water Act (1972) and the Safe Drinking Water Act (1974) also regulate certain aspects of hazardous waste management.

1.5 Code ofFederal Regulations

Once Congress passes legislation, federal agencies prepare and codify regulations which are published annually in the Code of Federal Regulations (CFR). The CFR has 50 Titles. Title 10 contains the Atomic Energy Act and related NRC and DOE regulations, Title 29 the OSHA regulations, Title 40 the EPA regulations, and Title 49 the DOT regulations. The federal government publishes the daily amendments and potential changes to the annual CFR and court interpretations in the Federal Register (FR). Several private companies sell computerized versions of the CFR as well as state regulations including recent updates and legal interpretations. Users can access these databases via modem, from floppy disks, or CD-ROM format. The computer databases allow for smaller storage space requirements, provide quicker access to specific regulations, and provide various advanced searching methods.

3 2.0 DEFINITION OF HAZARDOUS WASTE

Hazardous waste has been defined by RCRA as a "solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (1) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible or incapacitating reversible illness or, (2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported or disposed of or otherwise managed.. ." Other regulations may define hazardous waste differently, however RCRA sets the standard. The term solid waste includes solids and certain liquids or gases.

As shown in Figure I, the RCRA definition has a number of conditions and exceptions which are a result of overlap with other regulations and vestiges of earlier definitions of hazardous waste. Most of these exempted wastes are either regulated by other federal legislation or are regulated on the state and/or local level. The RCRA definition of solid waste does not include radioactive waste, because this waste is governed by the Atomic Energy Act. The flowchart illustrates the general philosophy behind defining and classifying hazardous waste. We advise the reader to consult the CFR prior to classifying a waste. As shown on the chart, RCRA classifies a waste as hazardous if the CFR lists it as a hazardous waste, or it has hazardous characteristics.

2.1 listed Wastes

EPA has defined and listed certain wastes as hazardous. A mixture of a listed hazardous waste and a non-hazardous solid waste is a hazardous waste. The "mixture rule" implies that any concentration of listed waste in a material makes it a hazardous waste. In recent years, the EPA has allowed a more flexible interpretation which classifies certain wastes based on characteristic hazardous components and concentration. Furthermore, one may be able to de-list a listed waste by following procedures in 40 CFR 260. RCRA regulates unrinsed containers, inner linings, and . any residue or soil contamination from hazardous waste as hazardous waste.

2.2 Non-Listed Wastes

If the waste is neither listed or specifically exempted, the generator must make a judgment based upon the hazardous characteristics of the waste. In some cases the generator can apply process knowledge of the waste or past experience to classify the waste as hazardous, otherwise the waste must be tested at an approved laboratory. Ifthe waste has any of the four characteristics below, it is hazardous:

A. Reactivity (coded DOO3) B. Corrosivity (coded DOO2) • normally unstable • aqueous pH < 2 or > 12.5 • ignites on contact with water • corrodes SAE steel at • releases toxic gases in contact greater than 0.25 in/year with water

4 C. Ignitability (coded DOO3) D. Toxicity (coded D###) • flash point < 60° C • capable of killing, • solid iginitable compressed injuring, or otherwise gas oxidizer impairing a living • listed as a Class A or Class B organism on contact explosive

The Toxic Characteristics Leaching Procedure (TCLP) is a laboratory method for estimating the leaching potential of a landfilled material. The evaluation of toxicity is based on the concentration of the specific chemical in the leachate. These chemicals and their maximum allowable concentrations are specified by Table 1,40 CFR 261.

2.3 Risk Assessment

Risk assessment is a quantitative means of evaluating the potential detrimental effects that an activity will have primarily on human health. Risk is a probability usually determined by obtaining a unit risk factor from toxicological data and using effective exposure data considering all pathways. Typically, the allowable target for a hazardous waste activity is a risk of lxlO-6 chance of a person getting cancer during a lifetime ofexposure due to the activity. Risk analysis has many applications, for example:

1. determining allowable concentrations in the TCLP analysis and in concentrations of allowable listed wastes in solid wastes 2. determining clean up levels ofhazardous waste sites under remediation 3. determining the best treatment strategies for remediating hazardous waste sites 4. permitting of new hazardous waste activities such as a new TSDF 5. factored into the Life Cycle analysis process in new product design

3.0 MANAGEMENT OF HAZARDOUS WASTES

Nearly every manufacturing or service operation generates hazardous waste. This waste can be managed on-site or be transported to a permitted treatment, storage, and/or disposal facility (TSDF). Using the manifest system, the EPA follows the trail of hazardous waste from its initial generation through final deposit or treatment.

3.1 Hazardous Waste Generators

Generators are required to comply with RCRA, OSHA and state and local regulations. If there is any release or potential release of toxic materials to the environment, generators will also have to comply with regulations in (1) the Clean Water Act, (2) the Clean Air Act, (3) SARA Title III, as well as a wide variety ofother industry specific regulations and controls.

The EPA has defined three separate classes of Hazardous Waste Generators: (1) Conditionally exempt generators, (2) small quantity generators (SQG's) and (3) large quantity generators . (LQG's). Several states have stricter definitions and tighter requirements for generators especially concerning accident preparedness and contingency plans.

5 Conditionally exempt generators (40 CFR 261) account for the largest number of generators and produce the least quantity of hazardous waste: less than 100 kg/month of hazardous waste and less than 1 kg/month of acutely hazardous waste, and store less than 1000 kg of waste on site. Although RCRA exempts them from most of the extensive permitting requirements, it still requires them to (1) identify their hazardous waste and (2) treat hazardous waste on-site or transport it to a permitted TSDF or recycling facility.

SQG's generate less than 1000 kg/month and less than 1 kg/month of acutely hazardous waste, and store less than 6,000 kg of waste on site. RCRA allows SQG's to store the wastes up to 180 days or 270 days if the nearest TSDF is more than 200 miles away. SQG's must obtain a 12 digit EPA ID number, follow proper waste transportation and storage requirements, and perform proper record keeping and reporting including tracking of manifests.

Large Quantity Generators (LQG's) are those that generate more than 1000 kg/month, or 1 kg/month of acutely toxic waste or store more than 6,000 kg of waste on site. RCRA requires these generators to comply with all requirements in 40 CFR 262-265 and related regulations outside RCRA. A LQG does not require a Transfer Storage and Disposal Facility (TSDF) permit . if they: (1) store only their wastes on-site (do not accept wastes from outside the facility), (2) store all wastes in a designated area, (3) store the wastes in proper containers properly marked as hazardous waste, and (4) comply with the requirements for owners or operators in Subparts C (preparedness and prevention) and D (Contingency Plan and Emergency Procedures) in 40 CFR Part 265.

3.2 Storage ofHazardous Waste

Proper storage of hazardous waste provides for appropriate separation of wastes, separation of non-compatibles, easy access to the waste, reasonable protection from vandalism, and appropriate secondary containment. These practices result in the reduction of the incidence and severity of accidents, simplified compliance, reduced/eliminated fines, and a more economical use of space and management time. Hazardous wastes are stored in many different types of approved containers including drums, overpack containers, tanks, and impoundments.

3.2.1 Underground Storage Tanks

There are approximately 1.5-2 million underground storage tanks (USn in the United States. UST's are regulated by the EPA through a mixture of statutory and regulatory provisions, or by the states to which the authority has been delegated. In many instances, inconsistent federal, state, and local laws have resulted in conflicts regarding the designation of "responsible parties." RCRA Subtitle I regulates tanks that contain a regulated Superfund substance or a liquid petroleum product with at least 10 percent of its volume underground (including piping connected to the tank). The statute requires tank owners to notify the state that they possess such tanks and directs the EPA to establish detection, prevention, release-detection requirements, and performance standards. Subtitle I does not cover approximately two-thirds of tanks because either other regulations cover them, or they do not pose a threat to human health and the environment. These tanks include:

6 • tanks holding 110 gallons or less • farm and residential tanks holding 1,100 gallons or less of motor fuel used for noncommercial purposes • tanks storing heating oil burned on the premises where it is stored • tanks on or above the floor ofunderground areas such as basements or tunnels • septic tanks and systems for collecting stormwater and wastewater • flow through process tanks • emergency spill and overflow tanks • surface impoundments and pits • tanks storing hazardous waste ( RCRA Subtitle C)

Approximately 200,000 USTs are leaking or have leaked at one time. The four major causes of releases are corrosion, faulty installation, piping failure, and overfilling. The majority of older tanks are bare steel and therefore galvanic corrosion is the most common fault. Federal regulations issued September 13, 1988, require that new UST systems be properly installed according to industry codes, equipped with spill and overfill prevention devices, protected from corrosion and equipped with leak detection devices. Tanks no longer in use must be decommissioned either by removal or by filling with an inert material.

3.3 Transportation ofHazardous Waste

The DOT regulates all aspects of the transportation, packaging, labeling, marking and placarding of hazardous waste under the Hazardous Materials Tracing Act of 1975 (HMTA), 49 CFR Parts 172-179. The HMTA was reauthorized in 1993, and governs all hazardous material shipments.

The DOT has five different divisions that govern the transportation of hazardous waste/materials:

1. Coast Guard 2. Federal Aviation Administration 3. Federal Highway Administration 4. Federal Railroad Administration 5. Research and Special Programs Administration

Under RCRA, the EPA is directed to establish certain standards for transporters of hazardous materials and to coordinate transpOltation regulatory activities with the DOT. The transportation of hazardous waste may also be regulated on the local level. State and local governments may require shippers and carriers to provide information about the types of materials they handle, origins and destinations of shipments, routes followed, miles covered in a given year, proof of insurance coverage, vehicle inspection dates, and drivers employed. Some states require hazardous waste registration, special training and certification, pre-notifications of shipments and periodic summaries of activities. Local authorities may also restrict the routes that hazardous waste transporters take.

3.3.1 Generator Requirements

The generator is required to ship wastes in the proper containers and accurately mark and label them (40 CFR 262). In addition, the generator is responsible for providing the

7 transporter with the proper placards per 49 CFR 172 Subpart F. The placards alert the first responders to a spill of hazardous materials. The placards are DOT approved and includes the hazard symbol, ID number, and UN hazard class number. The placards are placed on the ends and sides of motor vehicles, rail cars, and freight containers. Each container must be labeled with a hazardous waste label, which includes the generator's name and address, the proper shipping name, DOT hazard class, EPA hazard class, and waste type. Other appropriate labels are required such as "flammable" or "corrosive." Containers should be labeled so that the contents of a package can be identified if it is separated from its shipping papers.

3.3.2 Waste Manifests

The uniform hazardous waste manifest provides the mechanism for "cradle-to-grave" tracking of hazardous wastes. All hazardous waste shipments, except those from conditionally exempt SQG's must be accompanied by this form. States with EPA authorization can print their own version and they may have additional requirements. Part 262, Subpart D sets forth generator reporting and recordkeeping requirements, and hazardous waste import and export requirements are covered in Subpart E and F, respectively. When shipping interstate, the shipper should use the receiving states manifest. A copy of the manifest is kept by the generator, the transporter, and the owner of the receiving facility, and one copy is sent to the state. A second copy is returned to the generator upon arrival at the TSDF within 45 days of shipment. The manifest must be kept for 3 years or longer. SQG's are not required to submit copies of their manifests to the state but LQG's are. The generator must keep a log ofthe manifest numbers used.

The manifest requires information about the generator, waste type, DOT shipping description (49 CFR 173.2), waste quantity alternate acceptance facility, spill cleanup precautions, TSDF authorization numbers, billing information, listing of hazardous materials and non-RCRA regulated wastes, location of generator, hazardous waste numbers, physical state of waste, hazard code(s), and intended treatment or disposal method in code. It also requires the generator and transporter to certify that the wastes are in proper condition for transportation.

4.0 HAZARDOUS WASTE TREATMENT

"Treatment means any method, technique, or process, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume." (40 CFR 260)

A facility that performs the above is required to obtain a RCRA Part B permit or operate under Interim Status until a permit is obtained. There are certain exceptions to these requirements as specified in 40 CFR 265.

8 4.1 Treatment Options

Table 1 summarizes many of the hazardous waste treatment technologies that are available today. Many of these technologies have been adapted from other manufacturing fields such as chemical, mining, plating, water and waste water treatment, and concrete manufacture.

The four basic classifications of treatment technologies used here are physical, biological, chemical, and thermal. Physical treatments such as air stripping, sedimentation, and adsorption separate the hazardous constituent from the waste, resulting in a reduced volume of hazardous waste. Other physical treatments such as compaction and shredding reduce the size of the waste but not the total mass. Biological treatments such as bioreactors and composting result in the biological degradation of the hazardous constituents in a waste stream. Chemical treatments such as fixation, sterilization, and chemical oxidation destroy or reduce the toxicity or mobility of the contaminant by breaking and/or making chemical bonds in the hazardous constituents of the waste. Thermal treatments such as incineration, microwave treatment, and vitrification destroy the contaminants or reduce their mobility through intense heat.

The cost information provided in the table is intended to serve as a general guideline only. The costs are from published project costs, vendor estimates, and EPA compiled reports, and have been estimated in terms of 1994 dollars. The cost of any hazardous waste treatment method is highly dependent on the specific contaminant, concentration, quantity of waste to be treated, treatment goals, regulatory fees and restrictions as well as a myriad of other performance goals.

4.2 Selecting a Suitable Waste Treatment Facility

The generator is ultimately responsible for the waste if the transporter or TSDF fails to handle the waste properly. It is therefore very important to perform due diligence in investigating a TSDF. Below are some items to check out prior to shipping wastes anywhere.

Facilities need a RCRA Part B permit or interim status permit. One should obtain copies of all permits: state, local, air and water emissions and check to see that the application or permits cover the appropriate waste types and processes. In addition, check for:

• notices of violations and court actions • plant security, alarms, and emergency response • safety practices and written procedures • spill containment and groundwater monitoring • laboratory certification • personnel qualifications and experience • housekeeping and waste handling practices • financial stability: ability to pay for closure and post closure monitoring, insurance, ability to compensate injured parties and indemnity clients against loss

TSDF's are usually very specific in the type of waste that they can accept. Generators may rely on the services of a waste broker to arrange for treatment or disposal. The broker may also arrange vendor contracts, make arrangements for waste acceptance, and hire a transporter. The generator is ultimately responsible for the decisions the broker makes, and it is imperative that these selections be reviewed by a responsible member of the company.

9 4.3 Waste Disposal

The land disposal of hazardous waste is a highly discouraged practice in the United States. However, it is inevitable that some wastes be disposed of, because there is not enough treatment capacity nor complete treatment technologies available for all the wastes generated. Table IT summarizes the various disposal technologies currently available.

4.4 Remediation

Cleaning up hazardous waste sites involves the implementation of the CERCLA regulations. The clean up process involves investigation, feasibility studies, risk assessment, record of decision, design ofremediation systems, construction and implementation, and long term monitoring. This is covered in more detail in another chapter.

5.0 INFECTIOUS WASTE MANAGEMENT

Infectious wastes are biological wastes potentially contaminated with disease-producing organisms. They can pose a hazard to personnel who handle their disposal as well as to the general public. The EPA regulates medical waste management under RCRA Subtitle J promulgated in the Medical Waste Tracking Act (MWTA) of 1988. RCRA defines regulated medical waste as "...any solid waste generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in production or testing of biologicals..." (40 CFR 259). The MWTA directs the EPA to establish a demonstration program for managing and tracking medical waste. Much of the regulation is controlled by state and local government and varies widely from state to state. The EPA has seven recommended infectious waste categories:

1. isolation wastes (wastes from patients with communicable diseases) 2. cultures and stocks of infectious agents and associated biologicals 3. human blood and blood products 4. pathological wastes 5. contaminated sharps 6. contaminated animal carcasses, body parts, and bedding 7. unused sharps

Storage of infectious wastes should consider the integrity of the packaging, storage temperature, the duration of storage, and the location and design of the storage area. In selecting the appropriate packaging, the waste type, and handling and treatment methods should be taken into consideration. Protection from sharps is another important factor. The biohazard symbol must be prominent.

The EPA now requires that medical waste be sterilized prior to disposal to kill all pathogens in the wastes. Not all states enforce this yet for landfills. Incineration and steam sterilization are the most frequently used treatments, however, other processes are effective. There are approximately 6,700 on site incinerators at hospitals throughout the country and approximately 60% of waste is treated on site. Ifno longer hazardous after treatment, the material may be disposed of at a sanitary landfill or in the sewer if locally approved.

10 Biological indicators, which are a resistant strain of bacteria, test the effectiveness of treatment technologies. The indicators are placed in the waste prior to treatment and their destruction indicates the success of the treatment. Table I includes several infectious waste treatment options.

6.0 RADIOACTIVE WASTE MANAGEMENT

6.1 Sources

Radioactive wastes come from a wide variety of sources including nuclear power plants, government reactors, private industry, defense, and medical activities. Nuclear power waste sources include mine tailings, enrichment, fuel fabrication, reactor operation, spent nuclear fuel, and decommissioning of reactors. Industrial sources include production processes, research, manufacturing of radiopharmaceutical compounds, smoke detectors, and watch dials. Defense wastes include waste from manufacture of nuclear weapons and operation of nuclear powered vessels. The volume of defense waste generated is ten times that of commercial waste. Medical sources include wastes from medical diagnosis, treatment, and research.

There are three classifications of nuclear waste: high level (HLW), transuranic, and low level . (LLW). HLW are wastes that contain materials that were exposed to high level nuclear reactions or contain spent fuel from nuclear reactions. High-level wastes currently exist at federal government facilities such as the Hanford Reservation Center in Washington, the Idaho National Engineering Laboratory, the former Western New York Nuclear Service Center in West Valley, New York, and Savannah River (DOE, 1987).

Transuranic wastes, are compounds having more protons than uranium, e.g., plutonium. It is primarily produced by the reprocessing of spent fuels and in processing weapons grade material. LLW can be produced from any action involving radioactive material. The largest source is from mine tailings of uranium and thorium mines. Other sources mainly consist of contaminated clothing, equipment, structural material, cleanup materials, and a large amount of potentially contaminated material such as packing and paper and activated material.

6.2 Government Involvement

The Atomic Energy Act of 1954 (AEA) was the first legislation to include controlling radioactive waste management. As of 1986, eighteen different federal laws, governed radioactive waste management programs. These laws are enforced by the DOE, NRC, EPA, DOT, Department of the Interior, and various other smaller agencies as well as state mandated programs. Congress determined LLW to be a state issue. The Nuclear Waste Policy Act of 1982 established a . framework for developing and maintaining a system for HLW management and disposal in the US. As part of this act the US Treasury established a nuclear waste fund to receive payments for disposal fees. The DOE, through the Office of Civilian Radioactive Waste Management (OCRWM), develops geological repositories in compliance with 10 CPR 60.

The NRC reviews nuclear safety, siting, construction, and operation of repositories for the commercial sector. It also inspects the activities of the OCRWM. The NRC is responsible for regulating the receipt, possession, and the use and transfer of radioactive materials to protect public health and safety and the common defense and security of the United States.

11 ~- --", CFR Title 10 contains the NRC regulations. Part 20 provides the basic standards for protection from radiation. Other technical requirements are spelled out in 29 CFR 1926, OSHA "Safety and Health Requirements for Construction," the ASME code for pressure and piping, the American Concrete Institute "Code Requirements for Nuclear Safety Related Concrete Structures" (ACI 349-80) and relevant parts of the Uniform Building Code, the Uniform Mechanical Code and the National Electric Code.

The EPA is responsible for developing environmental standards to protect the health and safety of the public and the environment from potential hazards in the management and disposal of nuclear wastes.

6.3 Health Concerns with Radiation Exposure

Radiation exposure may cause severe acute health effects and chronic carcinogenic, teratogenic, or mutagenic effects. The principle of "as low as reasonably achievable" (ALARA) is the basis for the management of nuclear waste originally established in the Atomic Energy Act of 1954. The hazardous nature of a waste stream is measured by a number of factors:

1. activity level expressed as nanocuries/gram (nCi/g) of waste 2. the type of radioactive emission: alpha, beta, gamma 3. the half life of the waste isotopes 4. the relative physical stability of the waste 5. the mobility, leachability or in some cases volatility of the waste

Activity is measured in units of curies. One curie (ci) is equivalent to the disintegration rate of one gram of radium or 3.7xlO-lO disintegrations/sec. A rad is the dose of ionizing radiation that produces energy absorption of 100 ergs/gram in any medium. The relative biological effectiveness (RBE) is used as a measure of the specific biological damage caused by different types of radiation. It is used to calculate the rem (roentgen-equivalent, man) dose unit which is determined by multiplying the absorbed dose in rad by the RBE.

The EPA sets standards for exposure to radioactive materials in the environment: "the combined annual dose equivalent to any member of the public in the general environment resulting from: (1) Discharges of radioactive material and direct and indirect radiation from such management and storage and (2) all operations covered by part 190 [the uranium fuel cycle] shall not exceed 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other critical organ" ( 40 CFR 191). Waste management facilities must meet this criteria with "reasonable expectation" for 1,000 years and provide a "reasonable expectation" that releases will be limited for 10,000 years (40 CPR 191.16).

6.4 Disposal/Storage

Nuclear wastes cannot be detoxified or the hazards reduced like other waste through traditional treatment methods. The relative hazards of nuclear waste decrease over time such that proper storage of wastes over time can render the wastes non-hazardous. In many cases the disposal of nuclear waste is a storage problem. The treatment that is performed on the wastes usually involves either concentrating the wastes to reduce volume or stabilizing the physical form of the wastes to

12 reduce the mobility of the waste and simplify handling of the waste. Special precautions must be taken to avoid exceeding the "criticality" of the fissil material waste that could cause a runaway nuclear reaction.

Tables 1 and 2 summarize applicable treatment and disposal technologies for radioactive wastes. HLWand Transuranic waste present a health risk.

Disposal facilities for HLW and transuranic wastes must be on federally owned land and are regulated solely by the Atomic Energy Act regulations in 10 CFR part 60. The design concept for the disposal of HLW and transuranic wastes is to place the appropriate canisters in a deep geologic depository. The DOE has collected 10 billion dollars since 1998 in taxes to cover cost of building storage facilities. This is scheduled to begin in the year 2010, however the DOE has not yet cited an interim storage permit. This design concept includes a temporary storage facility known as a monitored retrievable storage or MRS. As listed in Table II, numerous other technologies have been suggested, however there is no current plan of further development of these alternative technologies.

6.5 Management ofLLW

The states have responsibility to provide for the safe management of LLW generated within their borders. States may license the LLW facility themselves or the NRC will license them. In addition to radiological protection, the states must regulate other aspects of the management of the facilities. 10 CPR 61 provides certain requirements for LLW facilities.

As of June 1994, only two sites were open for LLW disposal: Barnwell County, South Carolina, and Hanford, Washington. These two sites, however, accept waste from only a limited number of locations. Other disposal sites have submitted license applications, but the federal government under environmental pressure has been slow to approve them. The lack of permanent disposal facilities for LLW has caused the thousands of generators throughout the country to store the wastes at their own sites and may cause those generators without adequate storage capacity to shut down.

States have the right to regulate radioactive wastes that are exempt from NRC enforcement. The NRC exempts waste that:

1. cause <10 millirem exposure/year/person 2. cause <1 millirem of exposure to a large group/year 3. guarantees that no person receives >100 millirems/yr from all activities at the licensed facility

6.6 Transportation

The DOT primarily governs transportation of radioactive materials as specified in 49 CFR parts 173-178. These regulations specify performance criteria for packaging, package activity limits, driver training requirements, and routing restrictions. The NRC regulates the receipt, possession, use and transfer of byproducts and sources of special nuclear materials.

13 The NRC also sets standards for the design and perfonnance of packages used to transport high­ level radioactive materials and conducts inspection of its licensees. Other NRC regulations require the advance notification to the states of certain shipments and provide for physical security measures.

7.0 MIXED WASTES

Mixed waste (MW) is both hazardous and radioactive. Since mixed waste is considered hazardous under RCRA and radioactive under the Atomic Energy Act, both the NRC and the EPA work to address the management of the wastes. It is generated by pharmaceutical and biomedical research laboratories, universities and research laboratories, nuclear reactors, commercial facilities, analytical laboratories, DOEIDOD facilities, new TSDF's, and old disposal sites.

DOE estimates that it generated 22,000 cubic meters of mixed wastes in 1990 and has an inventory of 107,000 cubic meters of MW from past operations. It also estimates that they will generate 600,000 cubic meters remediating their sites. In contrast, commercial mixed waste is generated at a rate of 140,000 cubic feet per year, however, 70% of commercial mixed waste is incinerated and some materials are pretreated thereby further reducing the volume.

The generation and characteriz~tion of mixed wastes will likely increase as cleanup of CERCLA sites proceeds. While land disposal restrictions require treatment of mixed wastes, there is very little treatment or disposal capacity for mixed wastes in the U.S. A new mixed waste facility is scheduled to be opened in Hanford, Washington (see Table II), however it is only designed for mixed waste from on-site remediation activities. Consequently, most mixed waste is stored either on site or at designated facilities. Storing of mixed wastes can be problematic, because RCRA may not allow storing of hazardous waste under a facilities permit. Therefore, the EPA enacted a policy to relax enforcement of storage regulations of certain mixed waste generators. Most generators are not equipped to store mixed wastes which can pose a health and safety problem for workers.

8.0 CORRECTIVE ACTION

Corrective action refers to the investigation and remediation of releases of hazardous constituents from facilities that have or are seeking hazardous waste facility permits, or are operating under interim status. RCRA Section 3004(u) requires that any permits issued after November 8, 1984 require corrective action for all releases of hazardous waste or hazardous constituents from any solid waste management unit at the facility. Corrective action beyond the facility boundary must be performed where necessary to protect human health and the environment, as part of ongoing permit conditions.

The term "release" under RCRA is broader than as defined under CERCLA. It includes releases that are exempt under CERCLA and covered by the Clean Air Act and NPDES permits. The EPA broadly defines the term "release" to include a release of any amount to soil, surface water, groundwater, or air of any hazardous waste or hazardous material listed in Appendix VIII of 40 CPR Part 261.

Once there has been a release the corrective action process begins in five steps:

1. A RCRA facility assessment is made which is a desktop review of all information available, a site inspection, and optional sampling.

14 · 2. A corrective action order is given as specified in pennit conditions. 3. A RCRA facility investigation is performed to characterize the extent of contamination resulting from the spill including risk assessment and contaminant movement modeling. It includes feasibility studies of treatment technologies. 4. Interim measures that need to be taken to address releases ofimmediate concern. 5. A corrective measure study sets forth the proposed remediation alternatives. It is required if the contamination found exceeds an "action level."

40 CFR 254 discusses clean up levels required under Corrective Action. These levels are subject to interpretation based on health risk assessments.

9.0 WASTE MINIMIZATION

Waste minimization is modifying a process in order to reduce the volume or the toxicity of the waste generated prior to any treatment, storage, or disposal. It includes source reduction and environmentally sound recYCling, equipment and process changes, product reformulation, raw material substitution, and improvements in inventory control and housekeeping, maintenance and training.

Waste generators can achieve significant savings by reducing raw material consumption, waste disposal or treatment fees, and in tax credits given for waste minimization efforts. Federal law explicitly states that waste reduction is the preferred antipollution method. The 1984 amendments to RCRA promulgated a new Federal policy that wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expediently as possible. The EPA ranks management options as follows:

1. waste reduction 2. waste separation and concentration 3. waste exchange and recycling off site 4. energy/material recovery 5. incineration/treatment 6. secure land disposal

The EPA published guidance on hazardous waste minimization in the 1993 pUblication Hazardous Waste Minimization: Interim Final Guidance for Generators (EPN530-F-93-009). In this document the EPA lists six basic elements generators should incorporate into their waste minimization plan:

1. top management support 2. characterization of waste generation/management costs 3. periodic waste minimization assessments 4. cost allocation 5. encourage technology transfer 6. program implementation and evaluation

9.1 life Cycle Design

Environmental groups have criticized waste minimization in the past for being too narrowly focused and sometimes resulting in process modifications that only shift pollutants from one media to another. The solution to this problem is the concept of Life Cycle Design (LCD). LCD is a

15 method of product and process design that incorporates the minimization of waste production throughout every step of design and every step of the life of the product. This "cradle to grave" design method considers raw material extraction, product manufacturing, use, and final residual disposal. LCD establishes a more coherent means of integrating environmental requirements with more traditional concerns in product development such as performance, cost, cultural, and legal requirements.

Life Cycle Analysis (LCA) is one of the more promising systematic approaches for identifying and evaluating opportunities to improve the environmental performance of industrial activity. It is a useful tool for evaluating the environmental consequences of a product. LCA can be used in conjunction with LCD or be employed separately. By focusing on source reduction as well as reuse, recovery, and treatment, LCA gives a more accurate portrayal of the environmental impacts and true costs of a project. The EPA has put together a Life Cycle Design Manual as a guide for conducting and interpreting life cycle inventories.

10.0 Right to Know Laws

SARA Title III and the OSHA Hazard Communication Standard of 1985 established a regulatory program that requires disclosure of information to workers and the general public about the potential dangers of hazardous chemicals. They also require development of emergency response plans for chemical emergencies. Congress enacted these laws in response to the more than 2,000 deaths caused by the release of a toxic chemical in Bhopal India in 1984. The Clean Air Act amendments of 1990 placed additional responsibilities on the EPA and OSHA to enact legislation requiring further sharing of risk information and process hazard analysis. States and municipalities have passed additional right to know laws in response to specific companies not disclosing information about their process chemicals. Title III also requires the reporting of annual releases (42 USC 9061) and required that facilities that release extremely hazardous chemicals over threshold amounts must immediately notify the community emergency coordinator and the state commission. The EPA now requires monitoring for 320 chemicals. A proposed new rule could double the requirements to 633 chemicals that have to be monitored.

The majority of state right-to-know laws address both community and employee access to information about workplace hazards. The requirements of right-to-know laws most relevant to hazardous material planning and emergency response include (1) providing public access to information on hazardous materials present, (2) conducting inventories or surveys, (3) establishing record-keeping and exposure reporting systems, and (4) complying with container labeling regulations for workplaces.

OSHA now requires chemical manufacturers and importers to prepare Material Safety Data Sheets (MSDS's) for all hazardous materials produced or used. The MSDS's must be available to a state agency, local fire chief, and the public as part of their community right-to-know programs.

The format of the MSDS form, also known as OSHA Form 20, is up to the provider. It must contain at least nine elements:

1. manufacturer's name, address, and telephone number, chemical name, synonyms and formula 2. hazardous ingredients, approximate concentration and 1LV 3. physical data of product 4. fire and explosion hazard data for product

16 5. health hazard data 6. reactivity data 7. spill or leak procedures 8. special protective information 9. special precautions

11.0 Computer Usage In Hazardous Waste Management

The use of computers has become increasingly important in hazardous waste management. Computers provide updates to current regulations, prepare reports and manifests, perform complex modeling, perform risk assessments and LCA's, are design tools, track waste disposal, manage inventory, and provide various other convenience services. Approximately, 1500 software programs are available for pollution management activities. Several periodicals and trade magazines review the available software and provide annual summaries of the packages offered.

Regulatory agencies will often produce their own software which industry uses to do reporting. These software and databases are either on line or available by computer disk. These systems include databases, training and procedure review packages, pollution modeling programs, and emission calculation programs. One purpose for the software is to standardize calculations. Several regulatory agencies accept quarterly reports and release report information on computer disk. Computers provide direct access to environmental databases and provide on line reports to the EPA and other regulatory bodies. Databases are available either on floppy disks, CD ROM or through modem access. These databases provide chemical and toxicological data, current environmental regulations and interpretations, and abstracts of published research articles.

12.0 .Recommended Reading

1. Berlin, R.E., C.C. Stanton: Radioactive Waste Management, John Wiley and Sons, Inc., New York, NY 1989. 2. Bureau of National Affairs, various handbooks and CD ROM databases, Washington, D.C. (800) 372­ 1033. 3. Environmental Protection Agency: RCRA Orientation Manual, 1990 Edition, EPN530-SW-90-036, U.S. EPA, Washington, D.C., 1990. 4. Environmental Protection Agency: Risk Assessment Guidance for Supeifund, Vol 1 - Human Health Evaluation Manual, U.S. EPN54011-89/002, Washington, D.C., 1989. 5. Keolein, G.A., D. Menerey: Sustainable Development by Design-Review of Life Cycle Design and Related Approaches, J Air and Waste Management Assoc., 44, 645(1994). 6. LaGrega, M.D., P.L. Buckingham: Hazardous Waste Management, McGraw Hill, Inc., New York, NY, 1994. 7. Landrum, V.I.: Medical Waste Management and Disposal, Noyes Data Corporation, Park Ridge, NJ 1991. 8. Lindgren, G.F.: Guide to Managing Industrial Hazardous Waste, Butterworth Publishers, Woburn, MA 1983.

17 9. Phifer, R.W.: Handbook ofHazardous Waste Managementfor Small Generators, Lewis Publishers, Inc., Chelsea, MI 1988. 10. Plater, Z.J.B.: Environmental Law and Policy, West Publishing Co., St. Paul, MN 1992. 11. Wentz, c.A.: Hazardous Waste Management, McGraw Hill, Inc., New York, NY 1989.

Glossary ofKey Terms

HAZARDOUS WASTES are wastes that may cause or contribute to mortality or may pose a threat to human health. More detailed definitions are given in regulations such as RCRA

RISK ASSESSMENT involves determining potential health effects due to a specific chemical and potential human exposure. This leads to an estimation of the risk of developing an effect such as cancer due to a lifelong exposure.

MIXED WASTES contain both hazardous waste and radioactive waste.

CRF or Code ofFederal Regulations contains detailed information on Federal regulations including those dealing with the generation, treatment, reuse, storage, and disposal of hazardous waste.

RCRA or Resource Conservation and Recovery Act was initially passed by Congress in 1976. The original Act and its amendments cover aspects ofhazardous waste management.

Further Information (a partial list)

PROFESSIONAL ORGANIZATIONS:

Air & Waste Management Association American Academy ofEnvironmental Engineers American Chemical Society American Institute of Chemical Engineering American Society of Civil Engineers Water Environment Federation

JOURNALS:

JournaI of Air & Waste Management Association Environmental Science and Technology Enviromnental Progress JournaI of Water Enviromnent Federation JournaI of American Industrial Hygiene Association JournaI ofEnvironmental Engineering Journal ofEnvironmental Permitting Journal ofEnvironmental Regulation . Enviromnental Impact Assessment Review Pollution Prevention Pollution Engineering

18 Chemical Engineering National Environmental Journal The Generator's Journal Hazardous Materials Waste Business Magazine Hazmat World

CONFERENCES:

Hazmat Conferences Hazmacon

19 FIGURE 1. DEFINITIONS OF HAZARDOUS WASTES

GARBAGEJ REFUSE SOLID, LIQUID, SEMI -SOLID OR OTHERI OR SLUDGE CONTAINED GASEOUS MATERIAL 'WHICH IS: 1. DISCAl\DED 2. SERVED ITS INTENDED PURPOSE 3. A MANUFACTURED OR MINING BY DUCT

DOES 40-261.4 (al EXCLUDE YOUR MATERIAL FRCK REGULATION UNDER RCRA BECAUSE IT IS ONE OF THE FOLLOWING: 1. DOMESTIC SEWAGE THE MATERIAL IS 2. CW'A POINT SOURCE DISC'1i1\RGE t--_....._-.....'" NOT REGUIATED BY 3. IRRIGATION RETURN FLOW' ReM AS A SOLID WASTE 4. AEC SOURCE, SPECIAL NUCLEAR 5. IN SITU MINING WASTE 6. OTHER MM'ERIAI..S SPECIFICALLY iF P.Et1SED

N

IS THE MATERIAL RW EXEMPT 40 CFR 261.41A) BEC1IIJSE IT IS A: 1. MINING OVERBUl\DEN 2. HOUSEHOLD HAZARDOUS WASTE 3. OIL OR GEOTHERMAL WELL DRILLING FLUID 4. CHROME III PRODUCT THAT WON'T BECOME CHROME "r 5. DISCARDED WOOD FROM ARS.ENlCAL-TIlEATED WOOD GENERATORS 6. PETROLEUM CONTAMINATED WASTE REGUIATED UNDER 40 ern 280 7. SOLID "WASTE FROM ORE OR MINERAL PROCESSING $. AGRICULTURAL WASTE USED AS A FERTILIZER 9. FOSSIL FUEL COMBUSTION RESIDUAL 10. CEMENT KILN DUST 11. SOME INJECTED GROUNDWATER 12. USED eFe' S TO BE RECIAlMED 13. NON-TERNE FLATED OIL FILTERS 14. PETROLEUM REsIn USED TO MAKE ASPHALT

N

IS THE MATERIAL RECYCLED OR THE MATERIAL IS REGULATED REUSED IN THE FOLLOWING WAYS: UNDER ReM PART D 1. RECLAIMED OIL FROM HW" AS A SOLID NON-BAZARDOUS 2. REUSED IN AN INDUSTRIAL PRODUCT WASTE, NOT UNDER Pl1R.T C 3. BURNED AS FUEL UNDER 40-266 PA.1i.T E 4. SUBSTITUTED FOR A PRODUCT nOT APPL1ED TO THE LAND OR BURNED 5. RETURNED TO ORIGINAL PROCESS w:HERE IT WAS GENERATED 6. RECLAIMED OIL FROM 'H'i 7. Buro..'"ED AS FUEL UNDER 266 PJ...R.T E Tabl e 1. SummaryofHazardODS WtTas e rea t mentT ec h no I02les TECHNOLOGY CONTAMINANT TYPE REQUIREMENTS PRODUCTS COST ADSORPTION ORGANIC CONTAMINANTS G,WW, ADSORBENTS SUCH AS TREATED CARBONIS GW,OW ACfIVATED CARBON ADDED TO STREAMASTE CARBON, $2-3ILB. WATER AND FILTER OUT, COST CARBON CAN ABSORB HIGHLY DEPENDENT ON UP TO 5% ORGANICS CONCENTRATION AEROBIC BIOREACTOR READILY DEGRADABLE GW.IW TANK WITH AIR INJECTION AND INERTS. BIOMASS AND 200rrON TOXIC ORGANICS BIOLOGICAL POPULATION REDUCED BOD WATERS AIR STRIPPING PETROLLEUM W VACUUM AIR STREAM GASEOUS OR VARIABLE HYDROCARBONS CONDENSED CHLORINATED SOLVENTS CONTAMINANTS AND - WATER ANAEROBIC MORE RECALCITRANT AND W ANAEROBIC TANK AND INERTS BIOMASS, 200rrON BIOREACTORS HIGHER CONCENTRATION WW BIOLOGICAL POPULATION AND ACIDS AND REDUCED ORGANICS POSSIBLY METHANE INJECTION BOD WATER BIOLOGICAL LAND PETROLEUM AND WOOD S,SOL,SL OPENLAND AND MIXING LESSER 50rrON TREATMENT, TREATING WASTES EQUIPMENT CONTAMINATED COMPOSTING HEAPING MATERIALS CHELATING HEAVY METALS AND S TANK OR IN-SITU AND CHELATING TREATED SOIL AND N/A RADIONUCLIDES AGENTS LIQUID WASTES CHEMICAL OXIDATION WIDE RANGE OF SS,L,LW CHEMICAL OXIDANTS INCLUDE: INERTSAND 200rrON COMPOUNDS INCLUDE: OZONE, CHLORING, HYDROGEN INTERMEDIATE CHLORINATED HC'S, PEROXIDE, AND UV RADIATION PRODUCTS OF CYANIDES, MERCAPTANS, OXIDATION AND PHENOLS COMPACTION, BIOLOGICAL AND/OR SOL APPROPRIATE EQUIPMENT REDUCED VOLUME OF ON-SITE GRINDING, SHREDDING, RADIOIACTIVE HAZARD ORIGINAL WASTEBU BALING, SECTION, ACID NOT REDUCED DIGESTION HAZARD OR MASS ENCAPSULATIONOR TOXIC LEACHABLE L,OW,S, ORGANOPHILLIC POLYMERS AND ENCAPSULATED 100­ MICROENCASULTION COMPOUNDS AND SED BINDERS LANDFILLABLE OR 200rrON RADIOISOTOPES INCINERABLE WASTE EVAPORATION/ WIDE VARIETY OF L,WW EVAPORATION PONDS OR STILL BOTTOMS 10-100rrON DISTILLATION AQUEOUS OR SOLVENT DISTILLATION EQUIPMENT PURIFIED LIQUID BASED CONTAMINANTS INCLUDING RADIONUCLIDES GASNAPOR BIOLOGICAL HAZARD SOL FORMALDEHYDE OR ETHYLENE DISINFECTED WAS1ES: ON-SITE STERILIZATION OXIDE IN VESSEL. GROUND SOLIDS MAY STILL HAVE HAZARDOUS COMPONENTS INCINERATION: WIDE VARIETY OF G,S,SL, CONTROLLED HIGH INERTS, ASH, TRACE 500­ THERMAL OXIDIZERS ORGANICS, INFECTIOUS SED, SOL TEMPERATURE BUNER, FUEL, AIR AIR POLLUTANTS looorrON OF MANY TYPES WASTE AND NUCLEAR AND EMISSIONS CONTROL WASTES I ION EXCHANGE SOME METALS, CYANIDE W,WW APPROPRIATE RESINS TREATED WATER, 20ITON AND OTHER CONTAMINATED CATIONS/ANIONS RESIN INCLUDING RADIOISOTOPES IRRADIATION BIOLOGICAL HAZARD SOL ULTRAVIOLET RADIATION, DRY DISINFECTED WASTE: ON-SITE ENVIRONMENT MAY STILL HAVE HAZARDOUS COMPONENTS MAGNETIC SEPARATION METALS, RADIONUCLIDES WW,GAS MAGNETIC CORE, SELECTIVE TREATED WATER TO N/A, HIGH AND NITRATES ABSORBERS ORGANIC POLYMERS PPM LEVEL CAPITAL MEMBRANE PROCESSES: EXTREME roXICS NOT W SPECIALIXED MEMBRANES AND CONTAMINATED 20ITON ELECTRODIALYSIS REMOVED BY OTHER HIGH PRESSURE PUMPS OR DIRECT BRINE WATER AND REVERSE OSMOSIS AND PROCESSES...WORKS ON ELECTRIC CURRENT CLEAN WATER ULTRAFILTRATION SOLUTES MICROWAVE BIOLOGICAL HAZARD SOL MICROWAVE RADIATION AND DISINFECTED WASTE: ON-SITE TREATMENT MOISTURE USED TO HEAT WASTE, MAY STILL HAVE SHREDDED HAZARDOUS COMPONENTS TECHNOLOGY CONTAMINANT TYPE REQUIREMENTS PRODUCTS COST NEUTRALIZATION CONTAMINANTS WITH pH L,WW,S MIXING EQUIPMENT AND LIME, LARGE VOLUME OF 100­ <2 OR >12.5 SODA ASH, OR FREE ACIDS NEUTRAL MATERIAL 2oorrO~ ~'$ICAL TREATMENTS PRETREATMENT TO L,WW,S TANKS, LOADING AND CLEAN OR TREATED sorrol' ,UDING: SCREENING, REMOVE LARGE NON­ UNLOADING EQUIPMENT AND WATER REQUIRING FILTERING, HAZARDOUS COMPOUNDS OBVIOUS EQUIPMENT FURTHER TREATMENT CENTRIFUGATION INCLUDING AND CONTAMINATED RADIONUCLIDES SLUDGE PHYSICAL TREATMENTS DISSOLVED AND GW,WW SETILING TANKS AND CLEAN OR TREATED ISOrrO~ INCL: PRECIPITATION SUSPENDED SOLIDS AND FLOCCULANTS SUCH AS ALUM. WATER REQUIRING FLOCULATION/ SOME SOLUTES USUALLY AND POLYMERS AND SLUDGE FURTHER TREATMENT COAGULATION, GAS INORGANIC. MAY INCLUDE REMOVAL EQUIPMENT MAY AND CONCENTRATED FLOATATION AND RADIONUCLIDES REQUIRE AIR SUPPLY CONTAMINATED CLARIFICAnON SLUDGE PYROLYSISIMOLTEN WIDE VARIETY OF TOXIC L CONTROLLED NON-OXIDIZING CRACKED AND NfA SALT BATHS ORGANICS BURNER THERMALLY BROKEN DOWN ORGANICS SUITABLE FOR FUEL, FURTHER TREATMENT OR DISPOSAL SLURRY BIO-REACTORS HEAVY AND S.SL TANKS OR LAGOONS, MIXERS BIOMASS, lNERTS, 2oorrO\ RECALCITRANT ORGANICS AND SURFACfANTS INTERMEDIATES AND WET TREATED SOIL SOIL VAPOR PETROLEUM S VAPOR EXTRACTION EQUIPMENT GASEOUS 50-100rro'\ EXTRACTION HYDROCARBONS CONTEMINANTS AND CHLORINATED SOLVENTS CLEAN SOIL SOLIDIFICAnON HEAVY METALS SOME S,SL.L BINDERS. ASPHALTS. HYDRAULIC BETTER STRUCTURAL 30-80rrO\ ORGANICS AND CEMENTS. UREAFORMALDEHYDE MATERIALS, NON­ LEACHABLE LIQUIDS AND LEACHING SUITABLE RADIOISOTOPES FOR LANDFILLING OR LEAVING IN PLACE STABILIZATIONf HEAVY METALS, ACID S.SOL POZZOLANIC REAGENTS AND NON-LEACHING 30-80 FIXATION SLUDGES, SOME ORGANICS LIME SILICATES LANDFILLABLE MATERIALS OR REMEDIATED SITES STEAM STERILIZATIONf SMALL SIZE SOLID SOL HIGH TEMPERATURE STEAM AND DISINFECTED ON-SITE 'TOQ.AVING BIOLOGICAL HAZARD OVEN WASTEW; MAY STILL HAVE HAZARDOUS COMPONENTS Sl'EAMSTRIPPING VOLATILE AND SEMI­ W HIGH PRESSURE STEAM AND HIGH VARIABLE VOLATILE COMPOUNDS VACUUM EXTRAcnON CONCENTRATION STREAM AND CLEAR WATER Sl'EAMSTRIPPING, EX­ VOLATILE ORGANICS S HIGH PRESSURE STEAM AND HOT WATER WITH 32AZE-Cc SITU AND IN-SITU VACUUM EXTRAcnON CONTAMINANTS AND 200fCU3IC STERILE CLEAN SOIL YARD SUPERCRmCAL FLUID EXTRACTABLE ORGANICS S,SL,W HIGH PRESSURE AND RECOVERED 160rrO\ EXTRACTION l'EMPERATURE FLUIDS ORGANICS AND OXIDIZED ORGANICS THERMAL DESORPTION PETROLEUM S.SL THERMAL DESORPTION OVENS, GASEOUS 50-100iO~ HYDROCARBONS, NATURAL GAS OR ELECTRIC CONTAMINANTS AND CHLORINATED SOLVENTS HEATERS, AIR POLLUTION STERILIZED SOIL CONTROLS THERMAL INACTIVATION BIOLOGICAL HAZARD SOL,L HIGH TEMPERATURE OVEN OR DISINFECTED WASTES; ON-SITE VESSEL MAY STILL HAVE HAZARDOUS COMPONENTS VITRIFICATION NON-SPECIFIC, ASBESTOS S,SED, HIGH TEMPERATURE AND/OR GLASSIFIED WASTES NfA AND RADIOACTIVE WASTE SOL HIGH ELECTRIC CURRENT AIR SUITABLE FOR EMISSIONS CONTROL DISPOSAL OR LEAVB IN PLACE G: Gaseous Waste GW: Contaminated Ground Water HC: Hydrocarbons L: Liquid Wastes OW: Oily Water S: Contaminated Soil SED: Sediments SL: Process Sludges SOL: Waste Solids W: Contaminated Water WW: Industrial Waste Water Table 2. Summary of Hazardous Waste Disposal Options DISPOSAL DESCRIPTION WASTE TYPE ADVANTAGES LIMITATIONS AlOlOVEGRADE VAULTS ENGINEERED LARGE LLW SEGREGATED EASY ACCESS TO WASTE VULNERABLE TO STEEL AND CONCRETE INTRUSION AND I STRUCTURE ABOVE EROSION NATURAL GRADEULTS AUGURED HOLES SHALLOW DRILLED CLASS C LOW LEVEL TESTED BY DOE, GOOD DIFFICULT TO REMOVE HOLES ABOVE WATER AT WORKER WASTES, SMALL TABLE PROTECTION CAPACITY BELOW GRADE VAULTS ENGINEERED LLW, SEGREGATED LESS VULNERABLE TO WASTE LESS STRUCTURE BELOW INTRUSION AND ACCESSIBLE GRADE DESIGNED TO BE EROSION COMPATIBLE WITH SOIL CARLSBAD, NM WASTE DOE PROJECT DESIGNED TRANSURANIC DEFENSE REMOTE, ALREADY IN CONTROVERSIAL ISOLATION PILOT PLANT TO HOLD SIX MILLION WASTES PILOT PLANT STAGE CUBIC FEET IN SALT FORMATION DEEP SPACE CANISTERS PLACED IN HLW STUDIED BY NASA AND INFINITE ORBIT OR INTO DOE SUN DEEP WELL INJECTION ACID WASTED PUMPED HLW AND TRANSURANIC WASTE FAR REMOVED WASTE NON· TO GREAT DEPTHS INTO BELOW CRITICAL LEVEL FROM ENVIRONMENT RECOVERABLE FRACTURED ROCK EARTH MOUNDED COMBINED ABOVE AND LLW,HLW USED IN FRANCE VULNERABLE TO CONCRETE BUNKERS BELOW GRADE INTRUSION AND DISPOSAL OF EROSION STRUCTUALLYSTRONG WASTE CONTAINERS HANFORD MIXED WASTE 427,000 CUBIC FEET MIXED WASTES FIRST AND ONLY MIXED SCHEDULED TO OPEN TRENCHED TRENCHES FOR WASTE DISPOSAL NOVEMBER, 1994 STORAGE OF MIXED WASTES FROM CLEANUP OF HANFORD SITE rrESHHET CANISTERS DROPPED SELF HEATING HLW REMOTE LOCATIONS, CONCEPTUAL THROUGH ICE MELT HEAT REMOVAL ONLY POTENTIAL ICE DOWN MOVEMENT IMPROVED SHALLOW WASTE PLACED IN LLW REQUIRED SINCE 1982, MORE COSTLY AND LAND DISPOSAL DEEPER TRENCHES WITH NOT ALLOWED IN SOME COMPLEX THAN OLDER IMERMEABLE CAP STATES TECHNOLOGY INJECTION WELLS INJECTION INTO POROUS HW, PETROLEUM WIDELY PRACTICED, POTENTIAL DRINKING CLASSES I, IV, V ROCK FORMATIONS NOT WASTES, SEWAGE, LLW SECURE WATER COMMUNICATING WITH CONTAMINATION, CLASS I GROUNDWATER SUBJECT TO LAND BAl\' LANDFILL WASTED PLACED IN HAZARDOUS AND SIMPLY PROVEN HEAVILY TAXED Al"'D SUBSURFACE CELLS MEDICAL WASTES PRE­ DISCOURAGED, WITH LINERS, COVER, TREATED OR NOT ULTIMATE LIABILITY. LEACHATE AND BANNED LAND BAN GROUNDWATER COLLECTION MONITORING AND VENTING DISPOSAL DESCRIPTION WASTE TYPE ADVANTAGES LIMITATIONS MINED CAVITIES HALLOWED OUT LLW NO INTRUDER HARD TO ACCESS REGIONS IN MINERAL ACCESSIBILITY DEPOSITS ,"IODULAR CONCRETE USE OF AN OVERPACK LLW WASTE CAN BE EASILY CONTAINERS OR "MINI VAULT"TO REMOVED ENCASE DRUMS OCEAN DISPOSAL CONCRETE ENCASED IN LLW CHEAP, ARGUABLY LOW NOW BAN'NED, SOME DRUMS AT OCEAN RISK DRUMS LEAKED BOTTOM OCEAN PLATE DISPOSAL CANISTERS OF WASTE HLWAND TRANSURANIC GEOLOGIC STABILITY CONCEPTUAL, NOT BETWEEN CONTINENTAL GOOD FOR SOME SHELF AND MOVING ISOTOPES PLATES THROUGH HOLES DRILLED SALT MINES LIQUID WASTES PLACED NON-SPECIFIC CHEAPER, INACCESIBLE NON-RECOVERABLE INTO HOLLOWED MINES SHALE GROUT HIGH PRESSURE WATER HLW, TRANS WASTE RELATIVELY WASTE NO:,\· INJECTION CRACKS SHALE AND IMMOBILE, FAR AWAY RECOVERABLE THEN WASTE IN CEMENT FROM SURFACE SLURRY IS PUMPED INTO FORMATION

SHALLOW LAND WASTE PLACED IN LLW CHEAP AND EASY NOWBA},;\"ED DISPOSAL UNLIMITED EARTHEN TRENCHESUPT030 FEET DEEP SURFACE PLACEMENT OF WASTES LIQUID HAZARDOUS REDUCES VOLUME, LOW ESSENTIALLY SHORT IMPOUNDMENT INTO IMPOUNDMENTS WASTE, URANIUM MINE TECHNOLOGY TERM STORAGE, OPEN TO ATMOSPHERE TAILINGS HISTORICALLY PROBLEl'.fATIC YUCCA MOUNTAIN UNDERGROUND NUCLEAR SPENT FUEL, RETRIEVABLE WASTE, VERY EXPENSIVE, FACILITY RESPOSITORY FOR DEFENSE WASTES VERY REMOTE, HIGHLY CAPACITY LIMITED TO WASTE IN CANISTERS REGULATED 70,000 TO:'\S WILL OPEN I APPROXIMATELY 20ro HLW: HIGH LEVEL RADIOACTIVE WASTE CLASS A WASTE: LLW NOT REQUIRING STABILIZATION, SHORT HALF LIFE LLW: LOW LEVEL RADIOACTIVE WASTE CLASS B WASTE: LLW REQUIRES STABILIZATION BUT WILL DECAY WITHIN 100 YEARS HW: HAZARDOUS WASTE CLASS C WASTE: LLW REQUIRES STABILIZATION AND SHIELDING DURING HANDLP-\G. LONGER HALF LIFE